WILL YOU BE READY when the regulators come to examine your anti-money laundering practices?
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Customer due diligence and documentation |
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Ongoing tracking and updating of customer information |
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Risk scoring process to stratify your client base |
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Systematic process to identify suspicious transaction activities |
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Process to identify transaction activities requiring further review |
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Policies and procedures that reflect your activities and processes |
AMLSS is a comprehensive end-to-end scorecard assessment of your AML program. The assessment is performed over a two to four week period, depending on the size and scope of your bank. The assessment results along with broad recommendations and next steps will be presented to the bank executive management team. Subsequent practical implementation assistance can be offered as a follow up to AMLSS and will be discussed with you as part of the next steps.
The following is a sampling of areas included in AMLSS:
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Review institution-wide AML compliance program
- AML policies, procedures and training
- Client on-boarding and updating process and data collection requirements
- Client vetting and acceptance processes
- Identification of money laundering risk factors and overall risk rating methodology
- Documentation management
- Account and transaction monitoring program
- Account monitoring exceptions research, reporting, and escalation processes
- SAR filing process
- Compliance with OFAC, FinCEN, Bank Secrecy Act, and Patriot Act requirements
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Evaluate alignment of processes with regulatory requirements, industry standards, and documented procedures
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Assess effectiveness of implemented compliance-related technology
- Client data collection and document management
- Client risk rating tools
- Automated account monitoring/surveillance system
- Case management tools for exceptions management
- Compliance related management reporting capabilities
- Integration of client, account, and transaction data across systems
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Evaluate data quality and consistency |